Private Wealth Investment Vehicles (SPF)

The société de gestion de patrimoine familial (Private wealth management company) has been created
by the law dated 11 May 2007 (the “SPF Law “) with the objective of creating a favourable framework
for the family wealth management by qualifying shareholders which are either:

• Individuals acting in the management of their private wealth, or
• Patrimonial entities (e.g. trusts, private foundations) acting exclusively in the interest of
private wealth of individuals;
• Intermediaries holding shares in the SPF on a fiduciary basis or in a similar capacity, on behalf
of qualifying shareholders.

The activity of the SPF is strictly limited to the acquisition, holding and disposal of financial
assets. The assets in which the SPF can invest include shares, bonds and other debt instruments,
cash but also investments in structured products, derivatives as well as put/call options on
securities, indexes and currencies.

The SPF cannot engage in commercial activity. It may hold participations in other companies, but
only to the extent that the SPF does not involve itself in the management of these companies. It is
also not allowed to render any kind of services or to grant interest-bearing loans even to
companies in which it holds participation.

Tax aspects
The SPF benefits from a subjective tax exemption and is thus not subject to corporate income tax,
municipal business tax, net worth tax and dividend withholding tax.

The SPF is however subject to a 0.25% subscription tax to be declared and paid quarterly to the
Administration de l’Enregistrement et des Domaines (minimum annual taxation of EUR 100 and maximum
annual taxation of EUR 125,000).

The SPF does not benefit from the Luxembourg double tax treaty network.
Given its specific and limited purpose, the SPF is not to be considered as a taxable person for VAT
purposes (with no right to deduct input VAT).

Each year, the domiciliation agent, a licensed independent auditor or an expert-comptable must
certify:

• that the SPF is held only by qualified investors;
• that the SPF respected its obligations as a paying agent with respect to the withholding tax on
interest.

Accounting aspects
The SPF is subject to the same accounting rules as the other Luxembourg commercial companies.